To Log or Not to Log

[Rerouted]

Question....I have a shot at flying a 14000 lbs Twin Engine Turboprop aircraft operated under part 91 as co-pilot. The PIC is an ATP. I am a CFI/II, with AMEL, Hi Perf endoresement etc. To the best of my knowledge, the aircraft does not require a two man crew - except that the insurer requires it. At 14000, it requires a type rating for PIC operations - the best I hoped for was SIC anyway - which doesn't look too promising either. Is there any way I can log any of this time? One FSDO says I can log it as Total time and Multi engine & Cross Country time, but not PIC or SIC. Another says I can't log any of it. After reviewing the regs, I can't see how I can log any of it either. I'd love to be wrong here. Anyone want to take a shot at this?
RR

 

[Cardinal]

I think you're basically stuffed, but with one caveat. An ATP can give dual instruction in any aircraft for whcih he holds a type-rating, regardless of instructor certificates or the lack thereof. Since it's all Part 91 I'd call every leg you fly dual received. That of course wouldn't work under 135. Note, I'm not a lawyer, nor do I play one on TV.

Edited to say, Who the heck knows?

 

[Rerouted]

61.167

I think you're referring to 61.167. Good point, after reviewing it, indeed this may work for part 91 operations. Thanks for the idea. Any other insights out there???

 

[350DRIVER]

Question....I have a shot at flying a 14000 lbs Twin Engine Turboprop aircraft operated under part 91 as co-pilot. The PIC is an ATP. I am a CFI/II, with AMEL, Hi Perf endoresement etc. To the best of my knowledge, the aircraft does not require a two man crew - except that the insurer requires it. At 14000, it requires a type rating for PIC operations - the best I hoped for was SIC anyway - which doesn't look too promising either. Is there any way I can log any of this time? One FSDO says I can log it as Total time and Multi engine & Cross Country time, but not PIC or SIC. Another says I can't log any of it. After reviewing the regs, I can't see how I can log any of it either. I'd love to be wrong here. Anyone want to take a shot at this?

We operate the 300 as well as the 350 and our hands are pretty much tied together regarding the logging of flight time. Even though all of the first officers at my company have received the required ground training, flight training, as well as the 135 SIC check ride with that "magic" sheet of paper that allows us to legally fly the 135 legs the FAA has said on numerous occasions that none of our "SIC's" can log any SIC time due to the fact that our ops specs does NOT require a SIC however it is a company policy as well as our insurance policy to always have a 135 qualified SIC in the right seat at all times(doesn't help you build time up very quickly).- Fortunately for you all your flying will be under 91 however I would be extra careful how you log the time even IF you are "qualifed" as a SIC..... We have a "few" SIC's who say that you CAN log the flight time as SIC BUT I differ in opinion due to the fact that not only is the aircraft type certificated "single pilot" BUT the company policy and insurance requirements cannot over ride our ops specs and the local fsdo agrees hands down.. Although to this day the PIC will argue and say to log all time as "SIC"..

I will have the PIC endorse my logbook as "company instruction for the upgrade)- another 75 hours or so and I will be 135 PIC and won't have to worry about this...... The FSDO has also said that you can receive instruction on BOTH 91 & 135 legs which I think someone has said that you can only log the "91" time which I believe is incorrect....(make sure he makes a notation so future employers won't question the "quality" of the time which you will be logging........)

Be careful however since you really don't want alot of "instruction" time is your books- fortunately we have quite a few of 91 legs in our other King Air's (which don't require a type)which are all PIC time so this offsets the instruction time in my books- I don't think it would look too great if you walk into a interview with ALOT of instruction received time BUT thats just my opinion and until you get a type rating you really don't have much of a choice.(in reality this is the only way you can log the time)- talk them into giving you the type if at all possible----

C H E E R S

3 5 0

 

[avbug]

Cardinal,

You need to review your regulations. An ATP may NOT give instruction in any aircraft in which he or she is type rated. An ATP may give instruction to other pilots engaged air transport service, which preculudes Part 91 operations. Additionally, the intent of that regulation is to cover instruction regarding air transportation operations, not instruction toward any certificate or rating.

See 14 CFR 61.167(b).

Rerouted, the FSDO gave you bad advice. You need to know that any information the FSDO gives you is not gospel, and is not necessarily correct. The FSDO has no authority to interpret regulation, and there are better sources of information than the inspectors there. Most of them most likely don't understand the regulation well, and can't advise you or interpret the CFR.

How could you possibly log time as category or class, such as airplane multi engine land, but have neither SIC nor PIC time (assuming it isn't instruction received)? That is nonsensical. If you can't log it as pilot time, you can't log it for category or class, either. The same for cross country time.

If you're not there as a pilot, you need to be receiving instruction in order to log the time.

Insurance requirements for a second in command do not qualify one as a required crewmember, nor do company requirements to the same effect. If the type certification for the aircraft requires a second in command, or the regulations under which the flight is operated require a SIC (eg, Parts 121, 125, 135, etc), then you may be able to log time if qualified to act as second in command.

 

[bobbysamd]

Logging time

I don't believe that you can log the time, either. Although the insurance company requires the SIC, the FARs control. The FARs determine whether or not you need the SIC.

What floors me in this discussion is the FSDO didn't say in which capacity you could log the time. I think of a logbook as a sort of double-entry bookkeeping system. Total time has to balance with crewmember time, e.g. PIC, SIC, F/E, dual received, etc. And, then, try logging the time, having your logbook reviewed, and getting that FSDO to stand behind its answer.

 

[Rerouted]

Ok...

Avbug - that's pretty much what I feared. From a career perspective, does a part time job flying this thing make sense from an experiential perspective, or if it's not loggable, it's not worth doing?

 

[Av8tor89]

What about logging SIC time if you're flying under part 91 with a typed PIC who is not typed for single pilot operations. In other words, the PIC has been typed in the aircraft, but opted to not demonstrate the ability to use an auto pilot in lieu of an SIC during the type ride; thus a second-in-command is required for all flight operations. Does this make any sense?

 

[JediNein]

If the insurance requires a second pilot, change the ops specs to require a second pilot. Doesn't matter if it is a Cessna 172, two pilots required by 135 ops specs means a captain and a first officer.

Read the articles on Airnet again, carefully. This is how the company operates using a SIC.

As for riding along, sometimes the PIC might just want to take a break and allow the right seat person to fly the airplane. That is loggable PIC time (not acting) as sole manipulator of the controls.

I've also heard of a pilot that kept a passenger logbook of all the time he spent in right seats not as PIC or SIC. The rumor is he showed it to his interviewer who seemed impressed at all the extra crew experience.

Fly SAFE!
Jedi Nein

 

[avbug]

Av8or89,

That would be the other case; if the PIC is not single pilot qualified in type and requires a SIC, then the SIC must be aboard and the SIC may log the time (if qualified to do so).

As this flight operation is conducted under Part 91, it doesn't appear that changing opspecs is an option (didn't sound like a Part 135 operation).

Jedi, if the right seat non-legit SIC is acting as sole manipulator of the controls, he or she can't log it as PIC, because he or she isn't rated in the airplane. In this case, a type rating would be required to log it, under 61.51(e)(1)(i). The aircraft requires a type rating, so even though the SIC (ride-along) has category and class ratings, a type rating is required in order to log PIC time in the airplane, as sole manipulator of the controls.